BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) )

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M for Review of its Safety Model Assessment Proceeding Pursuant to Decision And Related Matters. A (Filed May 1, 2015 A A A COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E IN RESPONSE TO PRELIMINARY SED STAFF DRAFT WORKSHOP 1 REPORT ALLAN D. JOHNSON ROBERT F. LeMOINE Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( allan.johnson@sce.com Dated: September 18, 2015

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M for Review of its Safety Model Assessment Proceeding Pursuant to Decision And Related Matters. A (Filed May 1, 2015 A A A COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E IN RESPONSE TO PRELIMINARY SED STAFF DRAFT WORKSHOP 1 REPORT Pursuant to ALJ Kersten s ruling on August 18, 2015, Southern California Edison Company (SCE respectfully submits these Comments in response to the Safety and Enforcement Division s (SED Preliminary Staff Draft Workshop Report, dated August 31, 2015 (Report. Except for the items described below, SCE believes the Report accurately captures the key details of what was discussed during the first Safety Model Assessment Proceeding (SMAP Workshop held on August 3, SCE requests that SED make the following revisions to the Report: 1. On page 3, in the third-to-last bullet point, the Report implies that SCE is currently prioritizing its mitigation spending by considering Risk Spend Efficiency. During the Workshop, SCE stated orally and in its written materials that while it intends to prioritize its mitigation spending considering the Risk Spend Efficiency, SCE has not yet implemented it and SCE will also consider other factors. Therefore, SCE requests that the second sentence in this bullet point which currently reads: SCE s mitigation spending is prioritized using this risk 1

3 spend efficiency be revised to instead state: SCE intends to prioritize mitigation spending by taking Risk Spend Efficiency into consideration. 2. On page 6, under the heading Risk Spend Efficiency, the Report again implies that SCE is currently prioritizing its mitigation spending by taking into account Risk Spend Efficiency. Here again, to clarify the current state of SCE s program, SCE requests that a sentence be added to the end of the Risk Spend Efficiency section on page 6 that states: As part of its evolving risk-based planning approach, SCE intends to prioritize mitigation spending by taking Risk Spend Efficiency into consideration. 3. On page 6 in the first full paragraph, the Report states: SCE said that its risk models are works-in-progress and that none of the models presented to the workshop have been implemented yet, although SCE also said that risk-based planning has always been part of its culture. The final phrase although SCE also said that risk-based planning has always been part of its culture presents a similar issue to that described in comments 1 and 2 above in that it may imply that SCE has been conducting some form of risk-based planning in the past (which it has not. Thus, SCE requests that the sentence be changed to read SCE said that its risk models are works-in-progress and that none of the models presented to the workshop have been implemented yet, although SCE also said that considering risk has always been part of its culture. 4. On page 6, the third sentence of the first paragraph of the Risk Spend Efficiency section of the Report states: Programs and projects are prioritized by the risk spend efficiency numbers, subject to various operational constraints. There are, however, several non-risk concerns that utilities must consider when prioritizing programs and projects. Therefore, SCE requests that the sentence be revised to state: Programs and projects can be prioritized by the risk spend efficiency numbers, subject to various operational constraints, and other non-risk considerations. 5. On page 6, in the first sentence of the second paragraph of the Risk Spend Efficiency section, the Report states: Since SCE s risk model calculates relative risk scores, a 2

4 risk spend efficiency score calculated as such does not have standalone physical meaning, such as lives saved per year per mile of pipeline. The last phrase of that sentence such as lives saved per year per mile of pipeline is not something that SCE stated during the Workshop. First, SCE does not operate gas pipelines, so this statement is not relevant to SCE s business. Second, SCE does not believe that expressing the potential outputs of risk modeling in terms such as lives saved per year per mile is productive, as it focuses too heavily on the potentially inflammatory subject of life-or-death catastrophic events. Therefore, SCE requests that the phrase such as lives saved per year per mile of pipeline be deleted from the Report. Respectfully submitted, ALLAN D. JOHNSON ROBERT F. LeMOINE September 18, 2015 /s/ Allan D. Johnson By: ALLAN D. JOHNSON Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( allan.johnson@sce.com 3

5 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M for Review of its Safety Model Assessment Proceeding Pursuant to Decision And Related Matters. A (Filed May 1, 2015 A A A CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E IN RESPONSE TO PRELIMINARY SED STAFF DRAFT WORKSHOP 1 REPORT on all parties identified on the attached service list(s A et al. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s or other addressee(s. ALJ Colette Kersten CPUC 505 Van Ness Ave. San Francisco, CA Executed September 18, 2015, at Rosemead, California. /s/laura Velarde Laura Velarde, Executive Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

6 CPUC - Service Lists - A Page 1 of 3 9/18/2015 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A SDG&E FOR REVIEW O FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: SEPTEMBER 17, 2015 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties JAMIE L. MAULDIN KATY MORSONY ADAMS BROADWELL JOSEPH & CARDOZO, PC ALCANTAR & KAHL, CA 00000, CA FOR: COALITION OF CALIFORNIA UTILITY FOR: ENERGY PRODUCERS AND USERS EMPLOYEES COALITION AND INDICATED SHIPPERS SHARON YANG NORMAN A. PEDERSEN, ESQ. SENIOR COUNSEL ATTORNEY AT LAW SOUTHERN CALIFORNIA GAS COMPANY HANNA AND MORTON LLP 555 WEST FIFTH ST., STE. 1400, GT-14E7 444 S. FLOWER STREET, SUITE 1500 LOS ANGELES, CA LOS ANGELES, CA FOR: SOUTHERN CALIFORNIA GAS COMPANY FOR: SOUTHERN CALIFORNIA GENERATION COALITION ALLAN D. JOHNSON DIANE CONKLIN SOUTHERN CALIFORNIA EDISON COMPANY SPOKESPERSON PO BOX 800 MUSSEY GRADE ROAD ALLIANCE 2244 WALNUT GROVE AVE. PO BOX 683 ROSEMEAD, CA RAMONA, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: MUSSEY GRADE ROAD ALLIANCE DONALD KELLY KEITH W. MELVILLE EXE. DIRECTOR SR. COUNSEL UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON ST., STE CENTURY PARK CT., CP32 SAN DIEGO, CA SAN DIEGO, CA FOR: UTILITY CONSUMERS' ACTION NETWORK FOR: SAN DIEGO GAS & ELECTRIC COMPANY THOMAS LONG STEVEN W. FRANK LEGAL DIR. LAW DEPARTMENT THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 785 MARKET ST., STE BEALE ST., B30A / PO BOXX 7442 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: PACIFIC GAS AND ELECTRIC COMPANY

7 CPUC - Service Lists - A Page 2 of 3 9/18/2015 WILLIAM JULIAN II UTILITY WORKERS UNION OF AMERICA ALMOND LANE DAVIS, CA FOR: UTILITY WORKERS UNION OF AMERICA Information Only ALICIA AGUILAR CASE COORDINATION LEGAL SECRETARY/PARALEGAL PACIFIC GAS AND ELECTRIC COMPANY HANNA AND MORTON LLP, CA 00000, CA FOR: SOUTHERN CALIFORNIA GENERATION COALITION (SCGC EVELYN KAHL MARC D. JOSEPH COUNSEL ADAMS BROADWELL JOSEPH & CARDOZO ALCANTAR & KAHL LLP, CA 00000, CA MICHAEL REIDENBACH MRW & ASSOCIATES, LLC PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA KAREN TERRANOVA GREG HEALY ALCANTAR & KAHL SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH ST., GT14D6, CA LOS ANGELES, CA CASE ADMINISTRATION ROBERT LEMOINE SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY LAW DEPT. PO BOX 800 / 2244 WALNUT GROVE AVE WALNUT GROVE AVE., RM 370 ROSEMEAD, CA ROSEMEAD, CA SHINJINI MENON CARL WOOD DIRECTOR AFL-CIO, NAT'L REGULATORY AFFAIRS DIR. SOUTHERN CALIFORNIA EDISON COMPANY UTILITY WORKERS UNION OF AMERICA 2244 WALNUT GROVE AVENUE, PO BOX S. NEVADA ST ROSEMEAD, CA OCEANSIDE, CA JOSEPH W. MITCHELL, PHD DONALD C. LIDDELL M-BAR TECHNOLOGIES AND CONSULTING ATTORNEY KIMBALL VALLEY RD. DOUGLASS & LIDDELL RAMONA, CA ND AVENUE SAN DIEGO, CA CHARLES MANZUK JAMIE K. YORK SAN DIEGO GAS & ELECTRIC REGULATORY CASE ADMIN CENTURY PARK COURT, CP 32D SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA CENTURY PARK COURT, CP32D SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECRIC COMPANY CENTRAL FILES SHELLY J. SHARP SAN DIEGO GAS & ELECTRIC COMPANY SR. DIR 8330 CENTURY PARK CT, CP31-E PACIFIC GAS AND ELECTRIC COMPANY SAN DIEGO, CA BEALE ST., B9A SAN FRANCISCO, CA MARTIN HOMEC MIKE CADE PO BOX 4471 INDUSTRY SPECIALIST DAVIS, CA ALCANTAR & KAHL 121 SW SALMON STREET, SUITE 1100 PORTLAND, OR State Service

8 CPUC - Service Lists - A Page 3 of 3 9/18/2015 CHLOE LUKINS CHRISTINE HAMMOND CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC - LEGAL, CA 00000, CA HAL KANE LEUWAM TESFAI SR. ANALYST, RISK ASSESSMENT CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC - SED DIV, CA 00000, CA MICHAEL COLVIN ANA M. GONZALEZ CPUC - SED DIVISION OF ADMINISTRATIVE LAW JUDGES, CA ROOM 2106 FOR: SED 505 VAN NESS AVENUE SAN FRANCISCO, CA ARTHUR J. O'DONNELL CHARLES H. MAGEE GAS SAFETY AND RELIABILITY BRANCH GAS SAFETY AND RELIABILITY BRANCH AREA ROOM 2106 CHRISTOPHER PARKES COLETTE KERSTEN GAS SAFETY AND RELIABILITY BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 2-D ROOM 5101 ED CHARKOWICZ ELIZABETH PODOLINSKY RAILROAD OPERATIONS SAFETY BRANCH EXECUTIVE DIVISION AREA 4-A ROOM 5306 JEAN SPENCER KELLY C. LEE MARKET STRUCTURE, COSTS AND NATURAL GAS ENERGY COST OF SERVICE & NATURAL GAS BRA AREA ROOM 4108 MATTHEW A. KARLE NATHANIEL SKINNER ENERGY COST OF SERVICE & NATURAL GAS BRA ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 4108 AREA 4-A ROBERT M. POCTA STEVEN K. HAINE ENERGY COST OF SERVICE & NATURAL GAS BRA GAS SAFETY AND RELIABILITY BRANCH ROOM 4205 ROOM 2106 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS